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Plea Withdrawal

7th Circuit Court of Appeals

Case Name: United States of America v. Adam Sprenger

Case No.: 19-2779

Officials: EASTERBROOK, WOOD, and KIRSCH, Circuit Judges.

Focus: Plea Withdrawal

Adam Sprenger pled guilty to production and possession of child pornography pursuant to a plea agreement. He now seeks to withdraw his guilty plea and invalidate the entire agreement on the ground that the legal theory upon which his production conviction rests is invalid. When Sprenger initially entered into the plea agreement, his admitted conduct was sufficient to provide the factual basis for his production conviction. He contends that’s no longer the case, and thus, he is entitled to withdraw his plea to that offense. The government agrees with Sprenger on this point, as do we, so we vacate his production conviction.

We do not agree with Sprenger, however, that he is likewise entitled to withdraw his plea to the separate possession offense based on his now-invalid production conviction. The plea agreement still provides an adequate factual basis for the possession conviction, which supports that Sprenger’s plea to the possession offense remains knowing and voluntary notwithstanding the invalidity of the production conviction. We therefore affirm Sprenger’s possession conviction, leaving the still-valid portions of the plea agreement intact.


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Derek A Hawkins is Corporate Counsel, at Salesforce.

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